Due Diligence Failures The most dramatic example of a failure to date has been the BNP Paribas debacle. The due diligence was good but management overloads what they were told. So how does due diligence work in … Read More
OPSEC best practice
OPSEC Best Practice By John McCarthy, CCP and OPSEC President When conducting OPSEC assessments and surveys for Department of Defense (DoD) and other Government acquisition programs include Supply Chain Risk … Read More
Effective Mobile Security in the Post-Snowden Era
Effective Mobile Security in the Post-Snowden Era The revelation in October 2013 that the US National Security had monitored the mobile phone calls of Germany's Chancellor Angela Merkel started alarm bells ringing … Read More
Appropriate Due Diligence
Appropriate Due Diligence Could this be the “Miss Manners” edition on due diligence? No – never! But it is about what is appropriate given the circumstances and time. We cannot get all of the information in … Read More
Over Reporting
Over Reporting A new hot topic is AML and SAR over reporting. Bankers and financial managers are both so spooked about not filing SAR’s and have such little knowledge of their clients that as soon as something … Read More
Check Them Out! Background Checks
Check Them Out! Background Checks, Step-by-Step, by William Hermann Follow this link to the amazon page: … Read More
Speaking Engagements – December 2014
Speaking Engagements - December 2014 January 7th – 11th, Texas A&M Law School IODD - Due Diligence Certification http://www.international-due-diligence.org January 26th - 27th, Dubai FATCA www.interfima.org … Read More
Due Diligence In The MENA
The topic is as fascinating as it is complicated, not just complex. I am sure; at least for me that is why I find the work fascinating. The first step is to understand the nature of the target of your research. … Read More
Speaking Engagements – November 2014
November 3rd - 8th, Anti Money Laundering, Nairobi KenyaINTERFIMAhttp://www.interfima.org/ November 25th - 27th, Amman JordanAmerican Anti-Corruption Institutehttp://www.theaaci.com December 11th – 12th, AML … Read More
The Ultimate Risk
The Ultimate Risk I have been traveling a great deal and advising some companies on due diligence processes to better ferret out unknown risks. In particular, I have been thinking about how to anticipate several … Read More
Understanding Your Competitor’s Slackers
Understanding Your Competitor’s Slackers The best way to understand a company is to look at the company from the point of view of those who wish to subvert the company. Exterior subversion can come in the form of … Read More
Scare at T2C Paris
Scare at T2C Paris After a short stay in Paris, all my stays are too Shortt. I began the day with packing and getting ready for an afternoon flight to Belgrade on Etihad, the airline that is either loved or hated. … Read More
FinCEN wants Natural Persons
FinCEN wants Natural Persons The Financial Crimes Enforcement Network (FinCEN), has proposing rules under the Bank Secrecy Act to clarify and strengthen customer due diligence requirements for: (i) banks; (ii) … Read More
FATCA and the Inadvertently Regulated
FATCA and the Inadvertently Regulated FATCA is a bad law at the wrong place at the wrong time and it will not be repealed. Not even the Republican Majority in the House and Senate can do it. FATCA was enacted as … Read More
Laundering Money with a Hedge Fund
Laundering Money with a Hedge Fund Today most retail banks have become very good and I do mean very good at spotting money laundering. They have been doing it for some time and most have got the hang of spotting … Read More
Goodbye Columbus by Phillip Roth
Goodbye Columbus by Phillip Roth Goodbye Columbus was the feature story in a collection of short stories published by Phillip Roth when he was 26, and he has now just celebrated his 80th birthday. I have read the … Read More
Financial Service Firms, Boom Goes The Balance Sheet
There have been a series of recent acquisitions of second and third tier financial services firms. The firms have included different types of firms such as insurance, family business management, securities, trust … Read More
Risks In Recovery Actions
Risks In Recovery Actions This item could also be called – when due diligence meets asset recovery. In every case, large or small, there are certain foundational events, constraints, and inputs that shape the … Read More
Using a Competitor’s Regulatory Breaches
Using a Competitor’s Regulatory Breaches It is a truth that people can be very honest in a dishonest way. Governments are on a mission to find breach of sanctions, money laundering laws, insider trading, and … Read More
Storm Survival
Storm Survival I was reminded this month when a Category 3 Hurricane struck Cabo San Lucas in Mexico that weather and geology can offer up some devastating and surprising circumstances. Weather, in theory, can be … Read More
Wireless Security Systems Can Be Hacked
Wireless Security Systems Can Be Hacked There has been a recent flurry of articles on wireless computers and computer security but it has come to light, with very little surprise that wireless security systems can … Read More
Payments From Questionable Clients
Payments From Questionable Clients I remember a comment from an old Russian General about doing business. He said, “I was not trained in modern management with motivational inducements, or in modern financial … Read More
Issues For Custodians
Issues For Custodians Proper funds, trustees, and escrow companies all use the services of a custodian. A custodian is an independent entity that holds on to an asset, or the title to an asset, on behalf of the … Read More
Due Diligence – Insider Trading
For me, the gimlet eyed investigator, it is getting to the point that one cannot trade on any information that is either not already public, or that comes from an ephemeral fiscal itch to invest. I understand the … Read More
Crowd Funding
Crowd Funding The rise of private equity investing and how it’s been facilitated by the growing number of crowd funding platform websites present a series of complications. The complications present themselves … Read More
Due Diligence in China
Due Diligence in China For many years FE&E, Inc had an office in China. We got to see the rise of the entrepreneurial China. We also got to see the future currents and I am sorry to say – we have been more … Read More
Mind Your Monkeys
Mind Your Monkeys We escorted a group of Russian business men on a meeting / vacation trip to Bali. We had our local people scout the hotel and the resorts areas. Runs were made to and from the airport as well as … Read More
Banks Have No Money for Small Businesses
Banks Have No Money for Small Businesses It is simple, with a recently announced 100 billion liquidity short fall for US and thus banks are not going to be lending to small businesses. This is on top of the … Read More
Exempt Entities
Exempt Entities There are a number of exempt entities from the BSA and AML requirements. Chief amongst these are government and quasi-government accounts. This is a surprise to many, but not to the criminals. … Read More
Bunch-O-Water Balloons
Bunch-O-Water Balloons All I have to say after many, many hours spent filling water balloons – used of course to ambush our children, friends, neighbors – and any others that happened to be in range, and may be … Read More
Speaking Appearances for L. Burke Files
Speaking Appearances for L. Burke Files 13th – 14thOctober East West Security Conference - Paris, France. www.cecexhibitions.com 15th – 16th October, INTERFIMA, FATCA – Dubai UAE. … Read More
L . Burke Files will be speaking at
Mr. Files will be speaking at: 13th – 14thOctober East West Security Conference - Paris, France www.cecexhibitions.com 15th – 16th ,INTERFIMA, FATCA – Dubai UAE http://www.interfima.org/fatca/ … Read More
Due Diligence: Our Client Has Been Sanctioned
It happened. As silly as it may seem it really did happen. One of our cherished client trust companies was working for a client that got sanctioned. That is when we got the call. When one runs an international … Read More
BNP Paribas, The Success of Due Diligence And The Failure Of Management
BNP Paribas, The Success of Due Diligence And The Failure Of Management I have just returned from a trip through Europe, the Middle East and Asia. As I traveled, the saga and ultimate fine with BNP Paribas … Read More
LinkedIn Premium as a Data Tool
LinkedIn Premium as a Data Tool LinkedIn is an undisputed success. It is a great tool for reaching out to professionals. I would even say that if you are not on LinkedIn and participating in some of your … Read More
Traveling In the United States
Traveling In the United States When setting up to travel within the United States I look at all of the cities and states we will be visiting and call up and speak to the different departments. They have been … Read More
A Fiber Optic Cable Was Cut
A Fiber Optic Cable Was Cut It was a short trip through Northern California. During the three days my cell phone did not work and twice in two different cities the restaurant took our credit card and used a pencil … Read More